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An economic interest group managing R&D&i projects through other entities has requested clarification on its status as a holding company and how to calculate the deduction pro rata. The Directorate-General for Taxes (DGT) has ruled that it is a mixed holding company and that the sale of shares does not constitute an ancillary activity.
This ruling clarifies that mixed holding companies must incorporate capital gains from the sale of shares into their pro rata calculations, preventing them from being treated as ancillary activities for tax deduction purposes.
The tax team reviews your specific situation.
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